Along with many other personal and professional disruptions this year, COVID-19 is impacting the regulatory environment for organizations with funding covered by the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (commonly called “Uniform Guidance”), and potentially subject to a single audit requirement. On the bright side, there has been an array of new federal COVID-19 programs funded to provide relief to communities as well as expansion of some existing program funding. Conversely, the compliance requirements for any new federal funding sources subject to single audit have not been finalized. Organizations with these new sources of federal funding (and auditors of those programs) could find that the timeline for performing that compliance work will be pushed back until the compliance requirements of those programs are better defined. This updated timeline is expected to be released in an addendum in the early fall to the 2020 OMB Compliance Supplement to be published in the coming weeks.
Remember, just because a program has been assigned a Catalog of Federal Domestic Assistance (CFDA) number does not automatically mean it is subject to single audit requirements. If you are the recipient of new federal COVID-19 program dollars, contact a Barnes Dennig representative and we’d be happy to review the most recent program updates and resources for application.
For those subject to single audit compliance, make sure to review the memo M-20-26 issued by OMB that addresses administrative relief offered in response to COVID-19. First, the OMB has provided an extension to many for submission of the annual single audit filing (6-month extension for those with normal due dates from March 30, 2020 through June 30, 2020; 3-month extension for those with normal due dates from July 31, 2020 through September 30, 2020). It also provides the flexibility to charge salaries and other project costs related to COVID-19 interruption to existing grants, as long as the organization exhausts other available sources of funding and documents its efforts to do so, including evidence of reduction in overall operational costs. Finally, the memo clarifies that any payroll costs paid with the Paycheck Protection Program (PPP) loans or any other federal CARES Act program must not also be charged to current federal awards (often referred to as “double dipping”).
Although the 2020 OMB Compliance Supplement has yet to be released, the consensus from experts is to expect additional challenges and time commitments in order to comply with single audit requirements in 2020.
If you have questions about these compliance requirements, or any other COVID-19 related legislation, relief efforts, or loan forgiveness, have a member of our COVID-19 team contact you at no charge here, or by calling 513-241-8313.